The IRS Administrative Summons as Pretext to Avoid the Need for a John Doe Summons (8/20/12)

I posted earlier today on my Federal Tax Crimes Blog a discussion of the John Doe Summons.  See The IRS Administrative Summons as Pretext to Avoid the Need for a John Doe Summons (8/20/12), here.  The topic of the discussion is a prominent part of the Federal Tax Procedure class.  I accordingly recommend that blog entry to readers of this blog, particularly students in my class.

The principal discussion of the IRS regular administrative summons and the John Doe Summons in the Federal Tax Procedure Book (2012 edition) at pp. 352-362 of the Footnoted version and 256-262 of the NonFootnoted Version.